"To induce members of the public like John Doe to assist with the police investigation of the shooting, Mr. Matzner, a close friend of Ms. Chasen's, offered a reward of $100,000 to any individual who had information leading to the identification and arrest of Ms. Chasen's killer," the complaint states.

"Also to induce members of the public like John Doe to assist with the police investigation, Mr. Levine, another close friend of Ms. Chasen, separately offered to start a reward fund that was to contain a minimum of $25,000 within a week."

Matzner, chairman of Palm Springs International Film Festival, told Courthouse News in an emailed statement that all the police uncovered was "a suspect who committed suicide, not an arrest nor a conviction."

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"The only evidence about which the Festival is aware is that the suspect possessed the gun that killed Ronni Chasen. That's not close to good enough," Matzner wrote. He added: "This is not about the money. It is about justice for Ronni Chasen."

Chasen took a lead role in securing film stars for the Palm Springs International Film Festival. One rumor circulating around Hollywood is that Chasen may have been killed by a hitman.

But Doe, who lived in the same apartment complex as Smith, on Santa Monica Boulevard, claims that on the night of the murder Smith made several self-incriminating statements that led him to believe Smith committed the crime.

Doe says he alerted "America's Most Wanted" after learning of the $125,000 reward.

According to the complaint, on Dec. 10, 2010, Beverly Hills police contacted Smith at the apartment complex, where "Mr. Smith drew his weapon and took his own life. Mr. Smith sustained a single self-inflicted gunshot wound to the head and died at the scene."

Doe claims that after an "exhaustive investigation" homicide detectives concluded that Smith acted alone and that the gun he used to commit suicide was the one used to murder Chasen.

Doe says that Matzner told the media he would pay the reward if the Beverly Hills Police Department said that it was "the correct thing to do."

Documents attached to the complaint indicate that the Beverly Hills PD considers the case "officially closed" and has concluded "through interviews, scientific evidence and ballistics" that Smith acted alone.

"On July 27, 2011, John Doe's counsel sent Mr. Matzner and Mr. Levine letters enclosing the Beverly Hills Police Department findings and requesting immediate payment of the offered rewards," the complaint states. "True and correct copies of these letters are attached as Exhibit C.

"Mr. Levine contacted John Doe's counsel and stated that he had not started a reward fund and that he did not intend to pay the reward of $25,000.

"John Doe's counsel has not heard back from Mr. Matzner, despite multiple attempts to contact him by telephone and mail.

"Mr. Matzner made an oral and/or written promise to offer the payment of a reward sum of $100,000.00 in return for information leading to the identification of Ms. Chasen's killer. Mr. Matzner thereafter acknowledged the falsity of his promise and his fraud by an admission of having no true intent to perform on his promise of paying the $100,000.00 reward offered."

Matzner said the Palm Springs International Film Festival would consider "making a decision about the reward" if there was evidence that placed Smith "at the scene or near the scene at the time of her death or any other evidence that connects him to the actual shooting."

"However, as it stands, the Festival is not convinced that this case has been solved, nor are many other people in Hollywood. If the police have any additional evidence against the suspect, they should share it," he said.